Financial Firms in the SEC's Crosshairs - Key Developments

Corey Schuster is an Assistant Director in the SEC's Division of Enforcement and Co-Chief of the Asset Management Unit. He supervises investigations concerning investment advisers, including those that involve offering fraud, undisclosed conflicts, performance advertising, subadviser due diligence, compliance issues, and trading practices. Prior to becoming an Assistant Director, Mr. Schuster served as a staff attorney and investigated matters relating to mutual fund performance, undisclosed compensation, misappropriation of investor assets, trade allocations, CDS manipulation, insider trading, and unregistered broker-dealer activity. Mr. Schuster joined the SEC from the law firms of Schulte Roth & Zabel LLP and Dickstein Shapiro LLP in Washington, D.C., where he practiced in those firms’ Securities Litigation, Regulatory, and Compliance practice groups, and he previously served as an Adjunct Professor of Law at Georgetown University Law Center. Mr. Schuster received his bachelor’s degree from the University of Michigan and his law degree from Vanderbilt University.

Dabney O’Riordan is a partner in Quinn Emanuel’s SEC Enforcement practice where she primarily focuses on securities-related government inquiries and litigation, particularly for private investment firms and other asset managers. Dabney has extensive experience managing investigations and litigation, in particular matters involving the asset management industry, including advisers to private equity funds, hedge funds, venture capital funds, mutual funds, ETFs, business development companies, and separately managed accounts. In addition to representing clients in connection with SEC and other government matters, Dabney provides compliance counseling to asset managers.
A more than seventeen-year veteran of the SEC, Dabney was the longest-serving leader of the SEC Enforcement Division’s Asset Management Unit (AMU), which is a nationwide unit of approximately 60 lawyers and industry experts that leads the SEC’s efforts to investigate and litigate issues involving the asset management industry. During her more than six years leading the AMU, Dabney supervised hundreds of investigations, gaining extensive experience managing complex investigations and making ultimate investigative and litigation decisions, including the AMU’s investigative priorities, which cases to pursue, settlement terms to recommend to the SEC, and when and how best to litigate cases.
In leading the AMU, Dabney also directed the SEC Enforcement Division’s efforts to address emerging issues in the asset management industry. This work included participating on key task forces, providing guidance to other senior officers throughout the Enforcement Division, regularly collaborating with the Division of Examinations and Division of Investment Management, and engaging with the asset management industry. Among other things, Dabney was a member of the SEC Enforcement Division’s Climate and ESG Task Force and provided advice on the SEC’s 2019 Interpretation Regarding Standard of Conduct for Investment Advisers and various rules applicable to the asset management industry, including Regulation Best Interest, the Marketing Rule, the Proposed Private Fund Adviser Rule, and the Proposed ESG Disclosure Rule for Investment Advisers and Investment Companies.
Before leading the national AMU, Dabney led the SEC Los Angeles Regional Office’s Enforcement program as Associate Regional Director, overseeing the office’s enforcement priorities, investigations, and litigation involving public companies, insider trading, brokers, and investment advisers. Prior to that, Dabney spent eleven years investigating, litigating, and managing matters within the SEC’s Enforcement Division, working on novel and complex cases involving a wide range of issues falling within the SEC’s jurisdiction and frequently working in parallel with the federal criminal authorities.
Dabney’s extensive experience at the SEC has enabled her to develop creative, effective, and efficient solutions. For example, Dabney conceived of and led the SEC Enforcement Division’s Share Class Selection Disclosure Initiative. The initiative, which afforded advisers set settlement terms if they self-reported certain conduct to the Enforcement Division, resulted in settled resolutions with over 90 investment advisers in under nine months and was praised by then-Chairman Jay Clayton as having “immediate and lasting benefits . . .”
Prior to joining the SEC, Dabney was in private practice focusing on business litigation and served as a law clerk to the Honorable David R. Thompson of the Ninth Circuit Court to Appeals. She received her J.D. from UCLA School of Law, and a B.A. magna cum laude from Wellesley College.

Kelly Gibson is the co-leader of the firm’s securities enforcement practice. She previously held numerous national and regional leadership roles at the US Securities and Exchange Commission (SEC), including serving as the acting deputy director of the Division of Enforcement, as leader of the Enforcement Division’s nationwide Climate and Environmental, Social, and Governance (ESG) Task Force, and as director of the SEC’s Philadelphia Regional Office. Kelly advises and defends public companies, financial services clients, and their executives in SEC, self-regulatory organization (SRO), and state enforcement matters, and in internal investigations. She is admitted in Pennsylvania and New Jersey only, and her practice is supervised by NY Bar members.
Leveraging her government and private practice experience, Kelly works in collaboration with the firm’s corporate and business transactions, investment management, white collar defense, and labor and employment practices to advise clients on regulatory and litigation matters.
She also uses her broad ESG enforcement and policy experience to counsel public companies and registrants as they develop proactive ESG strategies, create investment products, consider disclosure requirements, and identify investment opportunities.
As acting deputy director of the SEC’s Division of Enforcement, Kelly helped set enforcement priorities and assisted in supervising approximately 1,300 staff who investigate and litigate across a broad spectrum of nationwide securities matters, including issuer disclosure and accounting abuses; foreign bribery; investment advisory and broker-dealer violations; securities offering; market manipulation; insider trading; and crypto- and cyber-related misconduct. In this role, Kelly also oversaw the division’s Office of Market Intelligence and Office of the Whistleblower.
In addition, Kelly served as leader of the Division of Enforcement’s newly formed nationwide Climate and ESG Task Force, where she led task force members from across SEC headquarters, regional offices, and specialized units to evaluate tips, referrals, and whistleblower complaints on ESG-related issues, and to develop initiatives to proactively identify potential ESG-related misconduct involving public companies and registrants. Kelly also served as a resource for, and coordinated enforcement ESG efforts with, other SEC divisions and offices, and she met with other federal, state, and international officials regarding respective ESG priorities.
As director of the SEC’s Philadelphia Regional Office, Kelly led a staff of approximately 160 enforcement lawyers, accountants, and industry specialists who investigate and litigate the federal securities laws nationwide, and examiners with oversight in the Mid-Atlantic region of nearly 1,200 investment advisers with more than $13.5 trillion in assets under management, over 150 investment fund complexes, and more than 290 broker-dealers with over 14,275 branch offices.
Earlier in her tenure, Kelly served in the Division of Enforcement’s Market Abuse Unit as an assistant regional director and then as associate regional director of the SEC’s Philadelphia office, where she supervised enforcement efforts. Kelly began her career at the SEC in 2008 as a staff attorney and received the SEC’s Analytical Methods Award in 2016. During her tenure at the SEC, Kelly supervised, investigated, and filed actions involving a wide range of securities violations, and she closely coordinated with state and federal criminal authorities on numerous parallel investigations. Before joining the SEC, Kelly was in private practice, advising clients on internal investigations and commercial litigation matters.

Gregory S. Bruch represents public companies, audit committees and special committees, broker-dealers, hedge funds and asset managers, accountants and lawyers, and other institutions and individuals in connection with civil and criminal securities law enforcement, compliance and litigation.
Mr. Bruch is recognized as a leading attorney in the area of securities law regulation and white collar defense in the 2007-23 editions of The Best Lawyers in America?; in securities regulation and litigation in the 2006-22 editions of Chambers USA: America’s Leading Lawyers for Business; and is recognized as one of Washingtonian magazine’s “Top Lawyers: Securities” (2011-22). Additionally, he was named by Ethisphere magazine as one of the “2009 Attorneys Who Matter” and was ranked as a “Litigation Star” in Benchmark Litigation (2012-23).
Mr. Bruch has been lead counsel for securities enforcement and related matters for a number of leading companies and financial services firms, including Time Warner Inc., Adelphia Communications Corp., Cablevision Systems Corp., Hain-Celestial Corp., E*Trade Capital Markets, and Van Wagoner Capital Management. Mr. Bruch also maintains an active FCPA practice representing institutions and individuals in counseling and investigations, and served as an independent compliance consultant, corporate monitor, or counsel to the corporate monitor on six major matters. Mr. Bruch has an active litigation practice, including the representation of the former CFO of Indymac Bancorp and a former senior big 4 accounting partner in civil and criminal proceedings. In 2010, he led a trial team in obtaining a rare dismissal, following an administrative trial, of charges brought by the SEC Division of Enforcement against a former partner at a Big Four accounting firm. He has served as lead counsel in connection with securities litigation, including shareholder class actions, derivative actions, and ERISA class actions, against individuals and entities involved in the Delphi Corp., Zale Corp., The Mills Corp., Monster Corp., Biomet Corp., Indymac Bancorp, Capital One Financial, and Agfeed securities litigation proceedings. Mr. Bruch has served as lead counsel to numerous clients in resolving securities-related charges with the SEC or DOJ, including clients for whom further prosecution has been declined. He frequently counsels investment advisers and broker-dealers during inspections and examinations by securities industry regulators, and is regularly retained by boards and independent directors for special projects involving shareholder demands or other sensitive matters.
Mr. Bruch frequently speaks at conferences, symposia and seminars on securities regulation, financial reporting and disclosure, insider trading and securities offerings, internal investigations, and the Foreign Corrupt Practices Act. From 1999 through 2005, Mr. Bruch was an adjunct professor at Georgetown University Law Center, where he taught courses in federal securities law enforcement. Additionally, he has served as a consultant to foreign securities regulators and market participants, including the Russian Federal Securities Commission.
Mr. Bruch served 12 years with the Securities and Exchange Commission Division of Enforcement in Washington, D.C. At the SEC, Mr. Bruch was Staff Attorney, Senior Counsel, Branch Chief and, from 1995 through 2001, Assistant Director. As Assistant Director, he supervised attorneys who investigated and prosecuted some of the SEC’s most significant financial fraud and broker-dealer cases, as well as cases involving the Foreign Corrupt Practices Act, insider trading, market manipulation and public securities offerings. Mr. Bruch also supervised the Division of Enforcement’s delinquent reporting program, which enforced the periodic reporting obligations of public companies and the beneficial ownership reporting obligations of corporate officers, directors and major shareholders. In 2000, he received the SEC’s Stanley Sporkin Award in recognition of his contributions to the SEC’s enforcement program. Prior to co-founding the firm, Mr. Bruch was a partner at Willkie Farr & Gallagher LLP, where he served on the Washington Management Committee, and at Foley & Lardner LLP, where he chaired the Securities Litigation, Enforcement & Regulation Practice.
Mr. Bruch is a frequent speaker and panelist, whose speaking engagements include appearances at the Practising Law Institute, The Ray Garrett Institute, the American Conference Institute, Glasser Legalworks, the DC Bar Association, the International Bar Association, the American Bar Association, and the New York City Bar. He has been quoted in numerous media publications, including the Wall Street Journal, Washington Post, New York Times, Financial Times, Los Angeles Times, Bloomberg, Reuters, Dow Jones, National Public Radio, CBS Evening News, and Nightly Business Report.
Mr. Bruch was born and raised in Independence, Missouri. He graduated from Stanford University (AB History, 1982), and from the University of Iowa College of Law (JD with High Distinction, 1985), where he served as the Editor in Chief of the Iowa Law Review and received the Legal Scholarship Award from the law faculty. Following graduation, Mr. Bruch was a law clerk to the Hon. George E. MacKinnon of the United States Court of Appeals for the DC Circuit.

Adam Aderton is a partner in the Litigation Department and a member of the Securities Litigation & Enforcement Practice Group. His practice focuses on regulatory enforcement matters and white collar defense. Adam has particular experience in regulatory inquiries and litigation involving the asset management industry, including matters involving private equity funds, hedge funds, venture capital funds, mutual funds, ETFs, business development companies, and separately managed accounts. In addition to representing clients in connection with SEC and other government examinations, investigations, and litigations, Adam provides compliance counseling to asset managers.
Adam previously served as Co-Chief of the Asset Management Unit in the Division of Enforcement of the U.S. Securities and Exchange Commission (SEC), where he led Enforcement’s engagement with the asset management industry and directed investigative teams across the country responsible for investigating and litigating actions involving private funds, registered funds, and separately managed accounts. In addition, he was a member of Enforcement’s Climate and ESG Task Force. As Co-Chief of the Asset Management Unit, Adam led investigations resulting in many of the most significant SEC asset management enforcement actions in recent years, including actions involving undisclosed conflicts of interest at one of the world’s largest hedge funds, allegations of a billion-dollar fraudulent fund valuation scheme, and the SEC’s first action in more than a decade charging an investment adviser with misleading disclosures regarding ESG investing. Adam also led Enforcement’s coordination with the Division of Examinations and represented Enforcement on significant rulemakings involving the asset management industry, including Regulation Best Interest, the Proposed Private Fund Adviser Rule, and the Proposed ESG Disclosure Rule for Investment Advisers and Investment Companies. Prior to joining the SEC in 2008, Adam practiced at an international law firm.